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TREAS/IRS

RIN: 1545-BK15

Publication ID: Spring 2014

Title: Nonrecognition of Gain or Loss on Disposition of Installment Obligations
Abstract: Proposed regulations will provide generally that a taxpayer does not recognize gain or loss under section 453B of the Internal Revenue Code on certain dispositions of an installment obligation if gain or loss is not recognized on the disposition under another provision of the Code. The proposed regulations also will clarify that a taxpayer must recognize gain or loss under section 453B on the satisfaction of an installment obligation when the taxpayer transfers an installment obligation (1) to the corporation that issued the obligation in exchange for stock in the corporation, or (2) to the partnership that issued the obligation in exchange for an interest in the partnership.
Agency: Department of the Treasury(TREAS)	Priority: Substantive, Nonsignificant
RIN Status: Previously published in the Unified Agenda	Agenda Stage of Rulemaking: Proposed Rule Stage
Major: No	Unfunded Mandates: Undetermined
CFR Citation: 26 CFR 1.453B-9
Legal Authority: 26 USC 453B 26 USC 7805

Legal Deadline: None

Timetable:

Action	Date	FR Cite
NPRM	12/00/2014

Additional Information: REG-109187-11 Drafting attorney: Arvind Ravichandran (202) 317-4718 Reviewing attorney: Michael J. Montemurro (202) 317-4718 CC:ITA
Regulatory Flexibility Analysis Required: No	Government Levels Affected: None
Small Entities Affected: No	Federalism: No
Included in the Regulatory Plan: No
RIN Data Printed in the FR: No
Agency Contact: Shareen Pflanz Attorney Department of the Treasury Internal Revenue Service 1111 Constitution Avenue NW, Washington, DC 20224 Phone:202 317-7006 Fax:202 317-4743 Email: shareen.s.pflanz@irscounsel.treas.gov